The H2020 projects SYSTEMIC and AGROCYCLE organised a joint workshop in Brussels, 30thMay, with participation of the European Commission, to discuss input tothe Commission (JRC) study now launched to propose criteria for whennitrogen-containing recycled nutrient products produced from animalmanure should no longer be considered to be ?manure ? in a processed form? under art. 2(g) of the EU Nitrates Directive.
As explained more fully in SCOPE Newsletter n°100,current interpretation of this article limits the use of recyclednutrient products (containing nitrogen and produced partly or completelyfrom livestock manure) to lower levels than use of virgin mineralfertilisers, in some circumstances in Nitrate Vulnerable Zones, soposing an obstacle to the development of nutrient recovery from manures.
Jan Huitema, Member of the European Parliament (Netherlands) underlinedthat this Nitrates Directive article is an obstacle to manure nutrientsrecycling and asked the European Commission to develop ?End-of-Manure?criteria.
Wim Debeuckelaere, European Commission, DG Environment, explained thatthe European Commission appreciates this problem and wishes tofacilitate the circular economy for manure nutrients, but also want toensure that the use of manure-recovered nutrient products does not leadto increased nitrogen losses to waters (contrary to the NitratesDirective objectives), nor to any other possible adverse effects(contaminants, phosphorus losses, greenhouse emissions ?). Therefore, astudy has been requested of JRC (European Commission Joint ResearchCentre, Seville) to assess these questions for differentmanure-recovered products. Priority will be given to types of productfor which agricultural application is expected to be ?safe? (list andorder to be confirmed):
- ammonium mineral products from stripping,reverse osmosis products (?mineral concentrates?), precipitated minerals(e.g. struvite);
- liquid fraction of solid/liquid separated manures and digestates;
- products with high organic content.
This JRC study will:
- propose criteria for manure-derived nitrogen-containing nutrientproducts which can be used under the same application limits as?chemical fertilisers? (art. 2(f) of the Directive), including definingappropriate methodology and carrying out biogeochemical modelling andfield trials;
- cover agronomic efficiency of such products (taking into accountthe form of nitrogen, climate and soil conditions), environmental andhealth risks (contaminants), atmospheric nitrogen emissions, risks ofnitrogen losses to water;
- develop a standardised protocol for testing nitrogen release, basedon lab analyses and field tests of manure-recovered nutrient productsand reference mineral fertilisers.
The JRC is currently developing the methodology, which will be presentedto the Nitrate Experts of the Member States early June. Comments willbe welcome on the proposed methodology until July. The final methodology will be presented to the Nitrate Experts group early September. To input data and information to this JRC study, see articles at top of this Newsletter.
The workshop then discussed agronomic, environmental and product qualityaspects, in rotating groups and in plenary, with the following workshopconclusions:
- For the JRC study:
- reference material: for all recovered mineral products, comparison should be made with the same ?virgin? (chemical) mineral fertiliser molecule(e.g. ammonium nitrate, struvite) in the same form (granule size forsolids, concentration for liquids), where this is today on the market;
- where a recovered nutrient product is a mineral with low levels of organics (e.g. < 1% Corgor some other cut-off level), then there is no point in carrying outtests or trials because it will behave exactly as does the same mineralof ?chemical? origin (within the variation of experimental or fieldresults);
- concentration (dry matter content) and purity are key requirements, and limits should be specified for all products in the JRC study;
- struvite will be applied for phosphorus content, so that resulting N application levels will be low (but do need to be taken into account);
- a considerable quantity of information is already available in existing studies and data;
- testing should be carried out in identical and controlled conditions,e.g. using lysimeters or pot-trials or incubation experiments, inpreference to field trials (which will not give representative resultsin the timeframe);
- in order to not prevent technical innovation, focus should be on product characteristics rather than on the recycling or manure treatment processes;
- limit specifications (cut-off values) for productcharacteristics are necessary to ensure clarity about what is or is notcovered by a given product vocabulary.
- Regarding product characteristics:
- pH is important for ammonium liquid products (and use recommendations should take account of this);
- consistent product quality: reliable product characteristics (level of organics, purity, concentration, pH, physical form ?) are essential for farmers;
- if recycled nutrient products are to replace mineral fertilisers (in the Nitrates Directive application limits) then their application constraints should be the same (4R stewardship);
- the SYSTEMIC product fact sheets (online at www.systemicproject.eu for comment)provide averages for product specifications. The range of value givingcomponents will be reported in a Systemic report, which will also givean overview on available information on agronomic effectivity andenvironmental risk assessments.
- ?Mineral concentrates? (reverse osmosis, RO)
- the SYSTEMIC fact sheet indicates an average carbon content of 0.6% Corg,an average dry matter content of 3.3% and an average total N content of0.7% N (wet weight). Participants underline that these products arethus not ?concentrated? and also that in reality these RO products can be very variable(varying levels of organics, range of dry content, variations innitrogen content and in nitrogen forms), depending on the process of theRO installation, so that definition of concentration and organicslimits are necessary for this product category, as well as informationto accompany the product;
- due to the relatively high water content of mineral concentrates,these are currently applied close by the manure processing plant. Thereis hardly any cross-border trade. Mineral concentrates could also beused to blend with other more concentrated mineral fertilisers toachieve a more consistent and more concentrated product.
- Products not indicated which should be covered in the JRC study:
- ammonium products recovered from manure evaporation and from air purification.
- Environmental impacts:
- cobalt is emerging as possible contaminant of concern;
- copper, zinc and cobalt are all micro-nutrients, so should not be limited but should require labelling above specified levels.
- Regulatory aspects:
- where recycled nutrient products from manures are authorised up to mineral fertiliser spreading limits, 100% of the recovered product N content should be counted (conservative = protective);
- other questions (beyond the status of certain products) need also tobe addressed, for example a consistent position between Member States /NVZ Action Programmes on the calculation of Nitrates Directive spreading limits for digestate where manure is only a part of the digester input, mixed with other materials, and more generally harmonisation of definitions and implementation.
The following follow-up actions will be engaged by SYSTEMIC:
- organise concertation with different technology suppliers and operators to develop product definitions(maximum/minimum levels) for ammonia salts from stripping/scrubbing andfor ?mineral concentrates? (reverse osmosis products), as well astolerances (these limits should be reliably respected in a product);
- in particular, for ?mineral concentrates?, minimum nitrogen content, nitrogen forms, minimum dry matter content, maximum organic carbon content must be defined;
- collect information and prepare Fact Sheets on digestate, liquid fraction of digestate, ammonia waters (from evaporators etc.).
All interested parties are invited to send literature and data relevant to this JRC study to SYSTEMIC systemic@wur.nl and ESPP info@phosphorusplatform.eu (by 29th July), who will collate and transmit to JRC ? see above.
SYSTEMIC ? AGROCYCLE workshop on?Fertilising products based on animal manure under the NitratesDirective and the circular economy?, Brussels, 30th may 2018 www.systemicproject.eu/policy-research-workshop-on-the-nitrates-directive-as-part-of-the-circular-economy SYSTEMIC Fact Sheets (drafts for comment) on?Struvite?, ?Ammonium sulphate?, ?Ammonium nitrate?, ?Mineralconcentrate? are on this website under Downloads -> Publications.
Reports from previous European Commission studies relevant to the Nitrates Directive http://ec.europa.eu/environment/water/water-nitrates/studies.html
Source: European Sustainable Phosphorus Platform (ESPP) eNews no 23 about nutrient recycling & stewardship.